CBAM, the Hamburg Declaration, and CSRD Adjustment: A Breakthrough Week in Global ESG

On January 26, 2026, Belgium, Denmark, France, Germany, Iceland, Ireland, Luxembourg, the Netherlands, Norway and the United Kingdom signed the so-called Hamburg Declaration^[1], committing to building 100 GW of offshore wind capacity^[2] in the North Sea by 2050. The investment package foresees installing 5 GW annually^[3] between 2031 and 2040, investments of 9.5 billion euros by the end of the decade, and potential mobilization of over 1 trillion euros by 2040. The agreement, prepared with the involvement of organizations such as Wind. Europe, NATO, and the European Commission, is set to power around 143 million households^[4] and reduce offshore wind costs by 30% over 15 years^[5], creating approximately 91,000 jobs^[6].

North Sea and Renewable Energy Turning Point

At the same time, Ember confirmed in its “European Electricity Review 2026” report^[7] that in 2025 wind and solar power generated more electricity^[8] in the European Union than fossil fuels for the first time – 30% compared to 29%, respectively. Solar energy increased production by 20.1% year-on-year^[9], reaching a 13% share, wind accounted for 17%, and all renewables combined for about 47% of EU generation. Simultaneously, Europe added 10 GW of new battery storage^[10], and the planned investment portfolio reaches 40 GW^[11], highlighting the growing importance of energy storage for system stability and prices^[12].

CBAM and Pressure on the Global Carbon Footprint

Since January 1, 2026, the Carbon Border Adjustment Mechanism (CBAM) has entered full operation^[13], turning reporting obligations into real financial burdens^[14] for importers of steel, aluminum, cement, fertilizers, hydrogen, and electricity. According to DG TAXUD data, by January 7, 12,000 operators had applied^[15] for authorized declarant status, and 4,100 companies received authorization before or shortly after that date^[16]. In the first week, 10,483 customs declarations^[17] covering CBAM goods were validated. The mechanism aims to level the playing field between producers covered by the EU ETS system^[60] and suppliers from countries with weaker climate policies, which already prompts countries like India, Thailand, and Singapore to strengthen their own emission pricing systems.

On February 2, 2026, the European Court of Auditors announced^[18] that the EU’s previous actions have not secured effective supply diversification^[19]. Thirty-four critical raw materials and 17 strategic ones were identified^[20], and the 2030 targets assume at least 10% extraction^[21]. The RESourceEU initiative includes projects worth around 2.15 billion euros^[22], which aim to reduce dependence on single suppliers by 30–50% by 2029^[23]. In this context, the importance of a circular economy and so-called urban mining grows significantly, especially concerning batteries and electronic waste.

Critical Raw Materials and the Circular Economy

On January 23, 2026, CATL, together with the Ellen Mac. Arthur Foundation, presented^[24] the report “Leading The Charge,” describing the circularity pathway for electric vehicle batteries^[25]. The Chinese manufacturer announced it recovers 99.6% of nickel, cobalt, and manganese^[26], and 96.5% of lithium, with planned recycling capacity reaching 270,000 tons annually^[27]. Forecasts predict recycling of about 1.2 million batteries annually by 2030^[28] and 14 million by 2040, with sodium-ion batteries enabling life-cycle emissions reductions of up to 60%^[29]. The development of recycling, battery second-life use, and the mandatory minimum share of secondary raw materials defined in the EU battery regulation aims to reduce pressure on critical raw material extraction.

ESG Regulation Adjustments and the Financial Market

At the regulatory level, the end of 2025 and beginning of 2026 brought a fundamental adjustment to the ESG reporting system^[30]. The European Parliament raised the thresholds for the CSRD and CSDDD directives^[31] to 1,000 employees and 450 million euros in annual turnover, excluding about 80% of companies previously potentially covered by CSRD^[32]. At the same time, the number of mandatory metrics in the European ESRS reporting standards was reduced by 61%^[33] and a temporary exemption from taxonomy reporting for financial institutions^[34] was introduced for 2026–2028. The highest penalties can reach 3% of global net revenues^[35], and large public-interest entities report data for 2025 and 2026.

In the market governance area, the ESG Ratings Regulation (2024/3005) will take effect on July 2, 2026^[36], establishing ESMA oversight over ESG rating providers^[37] and the obligation of their authorization to reduce methodological discrepancies and greenwashing risks. Consultations on the delegated act concerning penalties^[38] are scheduled until February 13, 2026, while existing providers must register with the supervisor by August 2, 2026^[39]. The UK will implement analogous ESG rating regulations^[40] on June 29, 2028. Simultaneously, the Canadian government announced its sixth green bond issuance on February 3, 2026^[41], increasing the program’s total value to 15.5 billion Canadian dollars^[42]. is expected to total around 530 billion dollars^[43] in 2026, with all sustainable instruments reaching approximately 900 billion dollars.

New CO₂ Standards and Further Signals

On February 3, 2026, the European Commission adopted a delegated act^[45] establishing the world’s first voluntary standard for permanent carbon dioxide removal certification, part of the Carbon Removal Certification Framework^[46]. The document covers technologies such as direct air capture of CO₂^[47], and capture and storage in bioenergy processes (BECCS)^[48]. After a maximum of four months of parliamentary scrutiny, the rules may enter into force^[49] in early April 2026. The standard aims to facilitate financing for CO₂ removal projects^[50], including planned CCUS installations in Poland, and to prepare the ground for potentially integrating so-called permanent carbon removals into the EU ETS by 2026.

Amid these main events, several weaker but significant signals have appeared^[51]. New climate lawsuits against energy companies are underway in Germany^[52], Italy is implementing the CRD VI directive requiring systemic ESG risk management by banks^[53], and Poland’s government is finalizing the National Energy and Climate Plan assuming 65–69% renewable energy^[54] in power generation by 2040. The Commission continues work on the EUDR regulation^[55], whose entry into force was postponed a second time – set for December 31, 2026^[56] for large and medium operators – due to the lack of a ready IT system for managing due diligence declarations. In the emissions allowance market, EUA prices reached 83 euros per ton on February 3, 2026^[57], with a consensus forecast of about 126 by 2030, and ESMA announced a priority focus in 2025–2026 on policing^[58] greenwashing practices of funds and issuers^[59].

Related posts:

• CBAM, CSRD Reduction, and Anti-Blackout Package: A Week Reshaping the ESG Landscape
• Greenwashing 2025: When Green Promises End Up in Court (and How to Avoid It)
• USA Withdraw from Paris Agreement, Europe Tightens Climate Policies
• EU Taxonomy Consultations, First CBAM Price, and Energy Price Pressure — A Week in ESG